Important Information Regarding Financial Conflict of Interest

Posted in Announcement

I am writing today to clarify the obligation of all faculty, staff, and AAPs regarding Financial Conflict of Interest (FCOI). The Georgetown University Financial Conflict of Interest Policy [“FCOI Policy”] applies to the entire university community. The FCOI Policy, Frequently Asked Questions and access to the electronic disclosure system for our mandatory, annual financial disclosures can found here.

An additional policy that applies to the Medical Center involves Industry Relationships and Interactions (new window).

The University’s conflict of interest policies and the federal laws and regulations we follow to preserve the integrity of university research. As responsible stewards of sponsored research funds, the policies are intended to eliminate the possibility that bias caused by personal financial interests would affect the design, conduct, and reporting of research. In keeping with the obligations we assume as recipients of federal funds, we are required to obtain financial disclosures from all “investigators,” meaning the PI and any other person responsible for the design, conduct or reporting of the research, of any financial interests they have that are related to their institutional responsibilities. These general disclosures must be filed once a year unless circumstances change, in which case updates are required within 60 days. We require that investigators keep their general disclosures accurate and current. We also ask that investigators submit study specific disclosures to assist in the determination of whether their private financial interests are related to the proposed research. We are required to obtain the financial disclosure, prior to submission of grant applications.

The university does not have the authority to waive this federal requirement.

We are required to determine if there are any significant financial interests related to the research that constitute a conflict of interest and, if so, to design and enter into a conflict management plan with the investigator to address that conflict, and to file a detailed report with PHS [and other agencies and organizations that have adopted the same rules] prior to the expenditure of any funds under the award. In addition, the PHS rules require conflict of interest training by all investigators, renewed no less than every 4 years, on the PHS rules and the institutional policies. Information on how and where to complete the mandatory FCOI training, which we provide electronically, is located here. We cannot open an account for awarded federal funds until all these steps are completed.

The requirement that investigators complete this training is personal to the investigator and may not be delegated to someone else. The obligation for each investigator to submit accurate and complete financial disclosures may not be delegated to someone else. It is falsification of the record and, too often, when a disclosure is submitted by someone other than the actual investigator, the submission has been inaccurate. Inaccurate, incomplete, and/or false financial disclosures may result in serious consequences for the individual investigator and for the institution.

The medical center recognizes that while appropriate and well-managed interactions between industry and the academic biomedical community can contribute to the public health, these interactions must be conducted in a way that protects the objectivity and integrity of the work of Georgetown’s faculty and staff. They must ensure that their objectivity is not affected by obligations owed to or benefits derived from the companies or organizations.

We ask that you all cooperate with these procedures in order to maintain the integrity and sustainability of our vibrant research enterprise.